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°®¶¹´«Ã½ submitted the following comments to USDA’s Animal and Plant Health Inspection Service regarding the American Rescue Plan strategic framework.

Dear Administrator Shea:

On behalf of the American Society for °®¶¹´«Ã½ (ASM), thank you for the opportunity to comment on the APHIS American Rescue Plan (ARP) Strategic Framework, which aims to build a surveillance system to inform actions to address SARS-CoV-2, emerging variants, but more importantly, other zoonotic disease threats in animals. We are pleased to provide input on how such a system can effectively prevent, detect, investigate and respond to threats to animal and human health. As one of the oldest and largest life science societies with more than 30,000 members in the °®¶¹´«Ã½ States and around the globe, our mission is to promote and advance the microbial sciences. ASM strongly supports a One Health approach to tackling emerging threats, from pandemic pathogens to antimicrobial resistant organisms, and we are pleased that the proposed plan is written with that perspective in mind.

For nearly 2 years, we have seen a tragic example of how emerging zoonotic diseases are a real and ever-present threat to global health and economic security. ASM is encouraged that this Strategic Framework brings many considerations to the urgent conversation regarding emerging threats of zoonotic disease from susceptible animals and from our environment. We support the ARP’s $300 million investment in a surveillance system as it will enhance the USDA’s ability to assist other federal agencies in preventing or limiting the next global pandemic. We offer below our comments on specific strategies and focal points of the framework, and we look forward to future engagement opportunities on this important endeavor.

Strategy 1.1: Improve our understanding of susceptibility, transmission and disease processes to plan effective prevention, surveillance and response activities.

Focus Area: Prevent and Detect

We strongly support expanding and strengthening partnerships among agencies within USDA, and between USDA and other federal agencies, especially those under the Department of Health and Human Services. It is essential that agencies with oversight over animal and human health communicate and effectively share data while protecting privacy and security. We also appreciate the inclusion of academic and private sector partners in the proposed plan, especially when it comes to diagnostics development, testing and characterizing the pathogen using technologies like next generation sequencing.

With respect to data, ASM encourages USDA and its partners to steward and enhance existing publicly accessible microbial databases, share sample collections with appropriate stakeholders, as well as to incorporate and utilize information regarding human and animal microbiomes to better identify vulnerabilities to zoonotic diseases. These actions are critical to the success of this program.

As APHIS strengthens its partnerships across other federal agencies, we encourage you to look at surveillance and laboratory capacity programs such as those at the Centers for Disease Control and Prevention (CDC), which have successfully integrated pathogen genomics into their work to detect pathogens at the human-animal interface.

Focus area: Investigate and Control Spread

We support the objectives in this area focused on workforce development and on ensuring a robust stockpile of vaccines, therapeutics, diagnostics and ancillary supplies. Increased investment in workforce development is critical to achieving the goal of a more powerful surveillance program. Robust surveillance, cutting edge technology and a connected network of labs are useless without skilled personnel to staff the labs and oversee and perform the testing and surveillance. Scientific societies like ASM can play a role in developing and training this workforce, and we encourage you to think beyond federal partners and consider the broader community.

A robust National Veterinary Stockpile is essential, including diagnostics and supplies, such as testing kits, swabs, pipette tips and reagents. We have witnessed testing supply shortages over the course of the COVID-19 pandemic. These same challenges in the supply chain can and will affect testing and disease mitigation in animals. Diagnostics enable and inform all aspects of infectious disease outbreak management in animals just as in humans—from surveillance and detection, to response, containment and recovery. As such, we must ensure that diagnostic supplies and ancillary provisions receive the same attention in our preparedness efforts as medical countermeasures.

Strategy 2.1: Strengthen measures for preventing emerging and zoonotic diseases at the human animal-environmental interface.

Focus area: Prevent

ASM is pleased to see that the framework recognizes the Global Health Security Agenda (GHSA) as a key component. ASM has supported the GHSA for many years and recently endorsed legislation in the House of Representatives that would strengthen the GHSA. A strong global health security agenda is critical for international engagement and capacity building in animal and human health. As an organization with an extensive global health program and scientists and public health workers on the front lines in countries all over the world, ASM understands firsthand the importance of securing our borders against both natural and intentional biological threats. The COVID-19 pandemic has taught us that our world is more interconnected than ever. What happens in environments in remote areas of the world can have a profound impact on public health because microbes are unimpeded by the construct of human borders.

ASM appreciates the Framework’s intent to identify and address research gaps to enable more effective zoonotic outbreak prevention and detection, including studies at the human-animal interface. Pathogens such as Influenza, Nipah and Hepatitis E continue to be grave threats to both animal and human health. Research to advance the development of new animal drugs intended for minor uses in major species or for use in minor species (MUMS drugs) is also essential to maintaining safe and productive interactions between human society and various microbiomes, including animals and their immediate environment.

ASM encourages expanded collaborations, such as working with One Health partners to study and track emerging diseases and antimicrobial-resistant organisms. Partnering with the Agricultural Research Service (ARS) and other agencies such as the U.S. Geological Survey, CDC and the National Institutes of Health is essential to developing a research agenda that ensures continued innovation and improved diagnostics. As noted above, the deployment of cutting-edge pathogen genomic sequencing technologies is critical to this work. Surveillance being conducted through the National Institute of Allergy and Infectious Diseases’ Centers of Excellence in Influenza Research and Response and the Centers for Research on Emerging Infectious Diseases would be invaluable to USDA. Innovative technologies in pathogen discovery should be deployed at USDA for more accurate an proactive surveillance.

Strategy 2.2: Plan and implement a risk-based, comprehensive, integrated monitoring and surveillance system.

As stated above, the use of next generation sequencing technology at USDA is critical to the rapid and accurate detection and characterization of emerging pathogens and variants. The adoption and deployment of technology and practices like that which have been put into place in other federal agencies such as NIH and CDC is essential. The use of these technologies to address influenza, which is one of the most significant threats to both animals and humans, has been transformative and improved the accuracy of predicting circulating flu strains and developing necessary countermeasures. Ensuring food safety is another area where this technology has proven invaluable, and the collaboration between CDC and USDA in this area is a good model for how this can be done under a framework like this one.

ASM and its members are grateful for the opportunity to share our perspective with USDA regarding this new investment in zoonotic disease surveillance. We look forward to the next steps in this endeavor and stand ready to assist you.

Sincerely,
Stacey L. Schultz-Cherry, Ph.D.
Chair, ASM Public and Scientific Affairs Committee

Advocate with ASM